Tax Seminar #3 – December 3 2012

John J. and Jane Doe
Form 9423 Collection Appeal Request
Soc.Sec.#s: 123-45-6789 & 987-65-4321
Question 15 - Explanation:
Taxpayer has paid all of his taxes and interest for each of the periods above. The only amounts due
are penalties, and interest on penalties. All of the late filing and late payment penalties are subject
to appeal and we believe that the penalties will be abated in full on appeal. The only penalties not
subject to appeal, estimated tax penalties, total $6,945. The Taxpayer can forward a check to
Revenue Officer Smith for that amount plus the interest thereon. Please provide us with the
computations.
Accordingly, the Internal Revenue Service is contemplating placing a lien on a Taxpayer who owes
(or shortly will owe) no money to the Internal Revenue Service. Placing such a lien on the Taxpayer
prior to their opportunity to have a full hearing on the matter with an Appeals Officer appears to be
premature and inappropriate.
Please note that Mr. Doe works in the real estate field. If a lien is placed against Mr. Doe, it will
affect his business and, reduce the amount of tax that he will pay to the Internal Revenue Service in
future years. Accordingly, this is not in the best interest of either the Taxpayers or the Internal
Revenue Service.
We understand that the Federal tax lien has not yet taken place and that we will have our Collection
Appeal Request hearing prior to the filing of that lien.
NOTE FORM 9423 INSTRUCTIONS:
THE COLLECTION OFFICE MUST RECEIVE YOUR REQUEST FOR AN APPEAL
WITHIN 2 DAYS OF YOUR CONFERENCE WITH THE COLLECTION MANAGER
OR WE WILL RESUME COLLECTION ACTION.
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